ML14036A095

Millstone Power Station, Unit 3, Request for Enforcement Discretion from Technical Specification 3.7.1.2, Auxiliary Feedwater System

ML14036A095
Person / Time
Site:	Millstone
Issue date:	01/28/2014
From:	Scace S E Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-043
Download: ML14036A095 (21)

Text

Dominion Nuclear Connecticut, Inc.Rope Ferry Rd., Waterford, CT 06385 JWEEE.E..W..

Mailing Address:

P.O. Box 128 JAN 28 2014Waterford, CT 06385don .conmU.S. Nuclear Regulatory Commission Serial No. 14-043Attention:

Document Control Desk MPS Lic/MLC ROWashington, DC 20555 Docket No. 50-423License No. NPF-49DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3REQUEST FOR ENFORCEMENT DISCRETION FROMTECHNICAL SPECIFICATION 3.7.1.2.

AUXILIARY FEEDWATER SYSTEMIn a teleconference call on January 26, 2014, Dominion Nuclear Connecticut, Inc.(DNC) informed the NRC staff of the need for a notice of enforcement discretion (NOED) from the requirements of Millstone Power Station Unit 3 (MPS3) Technical Specification (TS) 3.7.1.2, Auxiliary Feedwater System, which states, "At least threeindependent steam generator auxiliary feedwater pumps and associated flow pathsshall be OPERABLE,"

with ACTION c. stating for Inoperable Equipment, "One auxiliary feedwater pump in MODE 1, 2, or 3 for reasons other than a. or b. above. Restore theauxiliary feedwater pump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these ACTIONS arenot met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWNwithin the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."This NOED request (regular) is being made to avoid an unnecessary plant transient asa result of compliance with TS 3.7.1.2 ACTION c., by allowing an extension period of 36hours prior to initiating shutdown of the unit.The Facility Safety Review Committee has reviewed and concurs with this request.This NOED request was verbally approved by the NRC on January 26, 2014 atapproximately 1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br />. Per NRC Inspection Manual, Chapter 0410, "Notices ofEnforcement Discretion,"

DNC is required to submit a written request for the NOEDwithin two working days of the oral request for a regular NOED. This letter and itsattachments provide the information documenting DNC's request.The turbine driven auxiliary feedwater pump was restored to OPERABLE status at 0505on January 27, 2014. The compensatory actions to review existing transient combustible

permits, existing ignition

sources, racking breakers and perform areawalkdowns for the affected fire areas, and to brief the shift operators and the firebrigade lead on the significance of a fire in the affected areas were completed at 1800January 26, 2014.There are no regulatory commitments contained in this letter.bP-Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Page 2 of 2If you should have any questions regarding this submittal, please contact Wanda Craftat (804) 273-4687.

SincelS. E. ScaceSite Vice President

-Millstone

Attachment:

1. Request for Enforcement Discretion from the Requirements of Technical Specification 3.7.1.2 -Auxiliary Feedwater Systemcc: U.S. Nuclear Regulatory Commission Region 12100 Renaissance Blvd, Suite 100King of Prussia, PA 19406-2713 J. S. KimProject Manager -Millstone Power StationU.S. Nuclear Regulatory Commission One White Flint North11555 Rockville PikeMail Stop 08-C2ARockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Serial No. 14-043Docket No. 50-423ATTACHMENT 1REQUEST FOR ENFORCEMENT DISCRETION FROM THE REQUIREMENTS OFTECHNICAL SPECIFICATION 3.7.1.2.

AUXILIARY FEEDWATER SYSTEMMILLSTONE POWER STATION UNIT 3DOMINION NUCLEAR CONNECTICUT, INC. (DNC)

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1 Page 1 of 18Request for Enforcement Discretion from the Requirements ofTechnical Specification 3.7.1.2, Auxiliary Feedwater SystemIntroduction Dominion Nuclear Connecticut, Inc. (DNC) hereby requests the NRC staff to exercisediscretion not to enforce compliance with the Millstone Power Station Unit 3 (MPS3)Technical Specification (TS) 3.7.1.2, Auxiliary Feedwater (AFW) System.Discussion of the Requirements for which Enforcement Discretion is Requested Consistent with NRC Inspection Manual, Chapter 0410, "Notices of Enforcement Discretion,"

DNC herein provides a supporting description and justification for issuance ofthe requested notice of enforcement discretion (NOED).a. Specifically address what type of NOED is being requested (regular or naturalevent), which of the NOED criteria for appropriate plant conditions specified insubsection 03.03 of this guidance is satisfied, and how the licensee satisfied those criteria.

(also reference subsection 06.02 of this IMC)A regular NOED is being requested in accordance with NOED Criterion 03.03(b) ofNRC Inspection Manual, Chapter 0410, "Notices of Enforcement Discretion".

Criterion 03.03(b) involves the following condition:

"an unnecessary down-power or theshutdown of a reactor without a corresponding health and safety benefit."

This enforcement discretion is requested until 0150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> on January 28, 2014, for TS3.7.1.2 -Auxiliary Feedwater System.The request for enforcement discretion was made to avoid an unnecessary plantshutdown as a result of compliance with TS 3.7.1.2 ACTION c., by allowing anextension of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to the existing allowed outage time (AOT) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for aninoperable auxiliary feedwater pump. The 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> duration is needed to supportrepair and testing activities which are in progress.

See detailed information in section'e' below:b. Provide a description of the TS or other license conditions that will be violated, and, if applicable, state that adhering to the license would cause anunnecessary transient.

This description shall include the time remaining beforethe TS or license condition will be violated.

When a "regular" NOED isrequested, the licensee must show that granting the NOED request would avoidan unnecessary transient.

The TS that will be violated is MPS3 Technical Specification (TS) 3.7.1.2 -Auxiliary Feedwater System. The TS requires:

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 2 of 18"At least three independent steam generator auxiliary feedwater pumps andassociated flow paths shall be OPERABLE with:a. Two motor-driven auxiliary feedwater pumps, each capable of being powered fromseparate emergency busses, andb. One steam turbine-driven auxiliary feedwater pump capable of being powered froman OPERABLE steam supply system."If one auxiliary feedwater pump in MODE 1, 2, or 3, for reasons other than inACTIONs a. or b. is inoperable, ACTION c. of this TS requires the auxiliary feedwater pump be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these ACTIONS are notmet, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWNwithin the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.The basis of the TS requirement is to ensure a makeup water supply to the steamgenerators (SGs) is available to support decay heat removal from the Reactor CoolantSystem (RCS) upon the loss of normal feedwater supply, assuming the worst casesingle failure.

The AFW system consists of two motor driven AFW pumps and onesteam turbine driven AFW pump. Each motor driven AFW pump provides at least50% of the AFW flow capacity assumed in the accident analysis.

After reactorshutdown, decay heat eventually decreases so that one motor driven AFW pump canprovide sufficient SG makeup flow. The steam driven AFW pump has a rated capacityapproximately double that of a motor driven AFW pump and is thus defined as a 100%capacity pump.Given the worst case single failure, the AFW System is designed to mitigate theconsequences of numerous design basis accidents, including Feedwater Line Break,Loss of Normal Feedwater, Steam Generator Tube Rupture, Main Steam Line Break,and Small Break Loss of Coolant Accident.

In addition, given the worst case failure, the AFW is designed to supply sufficient makeup water to replace SG inventory loss as the RCS is cooled to less than 350°F atwhich point the Residual Heat Removal System may be placed into operation.

Enforcement discretion is requested to avoid an unnecessary plant transient as aresult of compliance with TS 3.7.1.2 action c., by allowing an extension of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> tothe AOT. The additional 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> duration is needed to support repair and testingactivities which are in progress.

At the time the enforcement discretion was verbally requested on January 26, 2014,MPS3 was at 100% power in Mode 1. On-line risk was GREEN. MPS3 was in TSAction statement 3.7.1.2.c.,

Auxiliary Feedwater System -One auxiliary feedwater pump inoperable which states: "Restore the auxiliary feedwater pump to OPERABLEstatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these ACTIONS are not met, be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 3 of 18c. Provide a description of the circumstances, including as a minimum:

likelycauses; the need for prompt action; the action taken to avoid the need for aNOED; and any relevant historical events. The historical events must include asa minimum, any other similar events at the plant, the last maintenance performed on the equipment or similar equipment, any outstanding amendment or TS change requests related to the NOED, and the last NOED request from theplant.On January 23, 2014 the MPS3 Turbine Driven Auxiliary Feedwater (TDAFW) pumptripped during the performance of surveillance procedure SP3622.3 as documented incondition report CR537862.

The likely cause of this test failure was insufficient forcebeing applied to the TDAFW pump control valve via the linkage to the governor.

TheTDAFW pump was declared inoperable at 1350 on January 23, 2014 and MPS3entered into T.S. 3.7.1.2 ACTION c., which states, "Restore the auxiliary feedwater pump to OPERABLE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these ACTIONS are not met, be in at leastHOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." Timely action is needed to avoid an unnecessary plant transient (i.e., plantshutdown to MODE 4) which would begin commencing at 1350 on January 26, 2014.Previous failed operational tests occurred on November 4, 2013 and December 18,2013. The investigation of these failures identified inadequate condensate removalfrom the steam supply lines servicing the TDAFW pump as the primary cause offailure.

Compensatory actions to improve condensate removal capability wereimplemented as described in operability determination OD 000561 and remain ineffect. Additionally, the testing frequency for the TDAFW pump was increased tomonitor its reliability until such time as repairs or redesign of the drain system could beaccomplished.

It was also determined that Terry Turbine Main Steam Control Valve3MSS*MCV5 should be disassembled and inspected as a near term action. Themaintenance activity on 3MSS*MCV5 was scheduled to commence on January 30,2014.Following the over speed trip of January 23, 2014, site resources were mobilized toinvestigate and correct the cause of failure on an around the clock basis. Extensive troubleshooting has been performed to focus repair and testing activities.

Vendorrepresentatives and Dominion Fleet experts have also been onsite supporting thiseffort.There are no outstanding amendment or TS change requests related to this NOED.Additionally, DNC has not previously requested enforcement discretion for MPS3.d. Provide information that shows the licensee fully understands the cause of thesituation that has led to the NOED request.

The licensee must understand anddetail all safety and security concerns when operating outside of its TS orlicense conditions.

Review of troubleshooting data identified insufficient force being transferred via thelinkage to the Terry Turbine Steam Supply Control Valve as the likely cause of the Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 4 of 18over speed trip on January 23, 2014. The following actions have been performed toinvestigate and correct any deficiencies:

1) the Terry Turbine governor has beenreplaced,

2) the Terry Turbine Main Steam Supply Control Valve (3MSS*MCV5) hasbeen disassembled, inspected, critical dimensions verified and re-installed with vendorsupport, and 3) the linkage from the governor has been inspected.

Binding in the fullopen position likely due to an incorrectly oriented Heim joint (Linkage element R2) andbearing wear at two additional points in the linkage were identified.

These deficiencies were addressed by removal and reinstallation of the Heim joint in the correctorientation, replacement of Linkage R1 including its spherical

bearings, andreplacement of the cam roller spherical bearing.

Freedom of movement was verifiedfollowing reassembly with no instances of binding throughout the full range of motion.The reassembly of the linkage was verified to be in accordance with its designconfiguration.

BasisCondition report CR537862 documented the "Terry Turbine tripped on over speed"that occurred on January 23, 2014. Review of the surveillance data identified that thevalve stem of the Terry Turbine Main Steam Supply Control Valve did not receivesufficient force to properly modulate the steam supply. As a result, the control valvedid not adequately control the turbine speed resulting in the over speed trip.Complex troubleshooting was performed using a Terry Turbine Tripped on Over speedFault Tree which identifies the following possible causes for the over speed trip:1. AOV Steam Supply stroke rate2. Moisture in main the steam supply3. Trip Valve (3MSS*MSV5) performance

4. Turbine operation

5. Work practices

6. Pump operation

7. Procedure weaknesses

8. Human Error9. Linkage performance

10. Control Valve performance

11. Design weaknesses

12. Governor performance The subject fault tree evaluates the twelve (12) possible causes of over speed trip.Items one (1) -eight (8), ten (10) and eleven (11) are determined as "not a factor" andthe basis is documented on the subject fault tree. Item 2, moisture in the main steamsupply was identified as a factor in the previous over speed trips on November 4, 2013and December 18, 2013. Item 2 (moisture) is not considered a contributor to theJanuary 23, 2014 over speed trip as the compensatory measures established as aresult of the previous trips were still in place. Video taken during the January 23, 2014test also showed a reduction in the amount of condensate being ejected from thevalve packing area during TDAFW pump startup.

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 5 of 18Prior to the commencement of the January 23, 2014 test, a strain gauge was installed to measure the force being applied to the actuator control valve stem from the linkageof 3MSS*MCV5 (Terry Turbine Main Steam Control Valve). Data collected via thestrain gauge indicated insufficient force being transferred through the linkage.

Sincethere was insufficient force on the stem to properly operate the control valve, possiblecauses 9 (linkage performance) and 12 (governor performance) were selected forfurther evaluation.

The steam supply to the Terry Turbine results in Terry Turbine rotor rotation, whichturns a spline within the governor.

This rotational force provides hydraulic pressure togenerate linear governor output. The linear output controls the turbine control valveposition; thereby controlling Terry Turbine speed. Governor output is transmitted tothe control valve stem via linkage.

Consequently, the low force measured within thecontrol valve stem was the result of either low output from the governor or a loss offorce measured in the transfer from the governor to the stem (i.e., within the linkage).

Low Governor OutputTo address the low governor output concern, the governor was replaced with a newlyrefurbished governor.

This alleviates any concerns with the governor.

Potential causes of low governor output are:" Incorrect oil used within the governor" Contaminants within the oil" Governor internal failuresOil samples were taken and sent to laboratory for analysis with testing to beexpedited.

This will determine if there were contaminants present or if the incorrect oilwas used. The replaced governor will be sent to the governor supplier ESI forrefurbishment.

Prior to refurbishment the governor will be inspected and tested toverify proper operation (i.e., expected output).Linkage Inspection (e.g., high drag, binding)Troubleshooting included a "pull test" of the linkage.

Three performances of this testresulted in recorded forces (i.e., 19.7, 24.5, and 23.3 pounds) less than the maximumacceptance criteria of 26 pounds. However, during full stroking of the linkage thecam-plate linkage Heim joint was binding at the full open position.

Visual inspection ofthis linkage identified the Heim joint was installed backwards (i.e., threaded endinstalled on bottom versus on top) and corresponding potential binding imprints on theassociated clevis. The Heim joint was reinstalled to the correct orientation.

Afterwards, freedom of linkage movement was verified subsequent to establishing thecorrect orientation with no signs of binding throughout the full movement.

Pull testsperformed following linkage adjustment and control valve maintenance resulted in asleft values of 13.3, 12.8, 13.2, and 12.9 pounds indicating a reduction in resistance.

Subsequent to the pull test, the linkage was further adjusted to set up correct valve Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 6 of 18stroke and seating.

After the linkage adjustment, three additional pull tests wereperformed to demonstrate continued freedom of movement.

The results from that testwere 13.6, 12.9, and 13.3 pounds. The consistent repeatability of the pull test resultsare considered indicative of effective resolution of linkage binding deficiencies.

Security concerns related information is included in Section J.e. Detail the proposed course of action to resolve the situation, so enforcement discretion is no longer required.

The actions to replace the governor, rebuild the control valve, and rebuild the controlvalve linkage to the governor have been completed.

The TDAFW pump has been runfor some operational checks and governor grooming with satisfactory results.

Theinitial operational test identified the need to replace the associated discharge reliefvalve. The final test sequence will be conducted after the relief valve repair and testingand when the turbine TDAFW pump has returned to standby conditions.

A full flowtest will be performed to satisfy the In Service Testing (IST) retest requirements andvalidate proper governor operation and control after the maintenance activity.

If theresults of this test indicate that additional tuning of the governor is required then theTDAFW pump will be shutdown and restarted in a maintenance mode to make thenecessary adjustments.

This process of retesting and adjusting is iterative and mayinvolve multiple cycles to obtain satisfactory performance.

Each cycle takesapproximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to implement.

Additionally a quarterly operational test, timeresponse

testing, and over speed testing will be performed.

Successful execution ofthe adjustment and retest sequence will lead to acceptable turbine performance andwill result in an operable TDAFW pump at which time enforcement discretion will nolonger be necessary.

f. Explain that the resolution itself will not result in a different, unnecessary transient.

Repairs of the TDAFW pump will not result in a different, unnecessary transient as theTDAFW pump is not an initiator of any event.Following

repairs, a full flow/operational readiness test of the TDAFW pump will beperformed in Mode 1 to demonstrate operability.

This test will be conducted as anInfrequently Conducted or Complex Evolution.

A safety analysis review of this testinghas concluded that there is no more than a minimal increase in the consequences ofan accident previously evaluated.

g. Explain that the licensee did not have time to process an emergency licenseamendment, or that a license amendment is not needed.A license amendment is not needed since this is a one-time request to allow repairand testing of the TDAFW pump. No permanent change to the operating license orthe TSs is required.

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 7 of 18h. Describe the condition and operational status of the plant, including safety-related equipment out of service or otherwise inoperable, and nonsafety-related equipment that is degraded or out of service that may have risk significance andthat may increase the probability of a plant transient or may complicate therecovery from a transient or may be used to mitigate the condition.

At the time the enforcement discretion was verbally requested on January 26, 2014,MPS3 was at 100% power in Mode 1. On-line risk was Green. MPS3 was in TSAction Statement 3.7.1.2.

Action c., Auxiliary Feedwater System.Additional Protected Equipment:

• 'B' and 'C' Reactor Plant Chillers and 'A' and 'B' Containment Vacuum Pumps (for'A' CDS Chiller overhaul)

" 'B' Emergency Diesel Generator Fuel Oil Transfer Pump ('D' Fuel Oil TransferPump breaker maintenance)

" 'B' Circulating Water Pump and VFD, 'B' Screen Wash Pump ('A' Circulating WaterBay Outage)* 'B' Control Building Chiller and support equipment

('A' Control building chilleroutage)* 'A' and 'B' EDGs and both MDAFW pumps (TDAFW pump outage).

Per OP-MP-601, Protected Equipment, when 3FWA*P2 is Out of Service:o Place Protected Equipment Barrier around 3FWA*P1A.

o Place Protected Equipment Sign on Breaker 34C1 6-2.o Place Protected Equipment Barrier around 3FWA*P1 B.o Place Protected Equipment Sign on Breaker 34D1 5-2.o Place Protected Equipment Sign on or Stanchion adjacent to the A train doorEG-24-1.o Place Protected Equipment Sign on or Stanchion adjacent to the A train doorEG-24-3.o Place Protected Equipment Tag on or Stanchion adjacent to EDG Sequencer 3RPS*PNLESCA.

o Place Protected Equipment Sign on or Stanchion adjacent to the B train doorEG-24-2.o Place Protected Equipment Sign on or Stanchion adjacent to the B train doorEG-24-4.o Place Protected Equipment Tag on or Stanchion adjacent to EDG Sequencer 3RPS*PNLESCB.

" Protect all safety related DC and AC sources in both trains (TSs 3.8.2.1 and3.8.3.1).

Time to Spent Fuel Pool heating to 200°F on loss of all cooling:

-92 hoursCurrent Spent Fuel Pool Temperature:

92.0°F Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 8 of 18Active LCO Actions requiring shutdown within 7 days:* T/S 3.7.1.2 action c. -72 hours for TDAFW Pump Inoperable (tripped on overspeed) (expires 1/26/14 at 13:50)Abnormal conditions

/ Key equipment out of service (OOS):" TDAFW Pump tripped on over speed during testing" 480V non-vital bus 32H intermittent Ground on 'C' Phase" 3SSR*RE08 non-functional due to 3SSR*CTV19B out of service" Non-safety related Battery 6 variable groundThe PRA condition is GREEN and it is expected to be GREEN for the duration of theTDAFW pump outage except for a brief period during TDAFW Pump Full Flow testingwhere it will be YELLOW. Risk significant equipment which is not or will not beavailable:

" 'D' Steam Line to TDAFW Pump" 'D' Diesel Fuel Oil Transfer Pump* 'A' Circ Bay* TDAFW PumpCore Damage Frequency (CDF) Allowed Condition Time (ACT) is 100.2 days andLarge Early Release Frequency (LERF) ACT is 159.6 days.i. Request a specific time period for the NOED, including a justification for theduration of the noncompliance.

The licensee shall include information thatshows its proposed course of action has a high likelihood of being completed within the proposed NOED period. The licensee must show the requested timefor the NOED is directly related to the time to resolve the situation.

This enforcement discretion is requested until 0150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> on January 28, 2014, for TS3.7.1.2 -Auxiliary Feedwater System.The request for enforcement discretion was made to avoid an unnecessary planttransient as a result of compliance with TS 3.7.1.2 action c., by allowing an extension of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOT. The additional 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> duration is needed to support repair andtesting activities which are in progress.

j. Detail and explain compensatory actions the plant has both taken and will taketo reduce the risk associated with the specified configuration.

Allcompensatory actions must be completed before the NOED CT begins.Compensatory measures used to reduce plant vulnerabilities shall focus onboth event mitigation and initiating event likelihood.

The objectives are toachieve the following:

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 9 of 181. Reduce the likelihood of initiating events, and2. Reduce the likelihood of the unavailability of trains redundant to equipment that is out-of-service during the period of enforcement discretion, and3. Increase the likelihood of successful operator recovery actions in responseto initiating events.An example is a situation in which a motor-driven auxiliary feedwater (AFW)pump has failed and risk insights have established that plant transient initiators may be risk-significant events because the plant has no primary feed-and-bleed capability and only limited secondary feed capability is available.

As acompensatory measure during the period of enforcement discretion, thelicensee may defer non-essential surveillances or other maintenance activities in which human error contributes to the likelihood of a plant trip andsubsequent demand on the remaining AFW pumps. Another example ofappropriate compensatory measures would be actions that increase thelikelihood of success in the manual alignment or start-up of equipment inresponse to an initiating event (e.g., positioning operators locally at equipment, "just-in-time training",

or additional contingency plans).The compensatory actions listed below are intended to increase operator awareness of plant conditions, to reduce the likelihood of losing redundant trains, and to reducethe likelihood and consequences of initiating events. To reduce the risk during theduration of the NOED, DNC will take the following compensatory actions:Implement the (a)(4) fire risk management actions in the Technical Requirements Manual (TRM) Section 7.4.1, Fire Related Safe ShutdownComponents for areas affected when TDAFW pump is OOS:o Review existing transient combustibles permits for the affected areaso Review existing ignition source permits for the affected areaso Perform an area walkdown of the affected areaso Evaluate all work requiring transient combustibles, hot work, orracking of breakers in the affected areaso Brief the shift operators and the fire brigade lead on the significance of a fire in the affected areaso Affected areas to be managed when the TDAFW pump is disabledare:" CB-1, Control Building West Switchgear Room -El. 4' 6"" CB-2, Control Building East Switchgear Room -El. 4' 6"" CB-8, Control Building Cable Spreading Area -El. 24' 6"" CB-9, Control Building Control Room -El. 47' 6"SCR- 1 .rC frnl Ri lrlinn Inftrllmant I nk-k Pnnm I Indlr flnnr 1=1UUU46' 6") and Rack Room -El. 47' 6"SB-2, Service Bldg North Cable Tunnel -El. 4' 6"SB-3, Service Bldg South Cable Tunnel -El. 4' 6"ESF-1, ESF Bldg South Cntmt Recirc Cooler Cub -El. -34' 9" to36' 6" Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 10 of 18" ESF-2, ESF Bldg North Cntmt Recirc Cooler Cub -El. -34' 9" to36' 6"" ESF-4, ESF Bldg East Piping Area -El. 4' 6"" ESF-7, ESF Bldg Mechanical Equipment Room C -36' 6" andESF Bldg Refueling Water Recirc Pumps Area -21' 6"" ESF-8, ESF Bldg North MDAFW Pump Area -El. 24' 6"" ESF-9, ESF Bldg South MDAFW Pump Area -El. 24' 6" and ESFBldg Mechanical Equipment Room D -El. 36' 6"* Include area AS-1 D, Auxiliary Building West Floor Area -El. 24' 6" in theimplementation of (a)(4) fire risk management actions." An operator is continuously staged at the station blackout (SBO) DieselGenerator (DG)* No planned unit transients, other than those described in the NOED for 4%downpower and associated full flow test, will be allowed for the duration ofthe NOED* No planned switchyard maintenance

" Protect the motor-driven auxiliary feedwater trains, main feedwater system,and condensate system* Removal of any of the components either due to scheduled or corrective maintenance will be monitored via the Risk Monitor (EOOS) and the MRule(a)(4) process" The Outage Control Center will be staffed 24/7 until the TDAFW pump isoperable and the TS action has been exited.k. Discuss the status and potential challenges to offsite and onsite power sources,including any current or planned maintenance in the distribution system andany current or planned maintenance to the emergency diesel generators.

Thelicensee must identify any specific transmission line configurations that mustbe maintained to ensure the availability of the grid for safe operation of theplant.Currently, MPS3 has no offsite or onsite power sources out of service, nor are anyplanned to be taken out of service during the time period when the proposed NOEDwill be used. Both MPS3 Emergency Diesel Generators, along with the SBO DieselGenerator, are available with no planned maintenance activities for the proposedNOED time period.1. Include the safety basis for the request and an evaluation of the safetysignificance and licensee should address the quantitative and qualitative aspects noted below. The numerical guidance for acceptance was established to augment qualitative arguments that continued operation of the plant duringthe period of enforcement discretion will not cause risk to exceed the leveldetermined acceptable during normal work controls and, therefore, there is nonet increase in radiological risk to the public. For licensee provided quantitative risk analysis, the licensee shall provide the effects on LERF. The following information should be provided to support this evaluation:

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 11 of 181. Use the zero maintenance PRA model to establish the plant's baseline riskand the estimated risk increase associated with the period of enforcement discretion.

For the plant-specific configuration the plant intends to operate induring the period of enforcement discretion, the ICCDP and ICLERP shouldbe quantified and compared with guidance thresholds of less than or equalto an ICCDP of 5E-7 and an ICLERP of 5E-8. These numerical guidancevalues are not pass-fail criteria.

For the degraded case with the subjectequipment out of service, the model should reflect, as best as possible, current equipment unavailability states (i.e., if other equipment is unavailable because of T&M, this should also be reflected in the analysis).

This riskcalculation should not be limited to the specific TS relief in question, butrather, the total risk of continued operation for the specific configuration ofthe plant.The MPS3 zero-maintenance internal events risk monitor PRA model, M310R02,was used to estimate the impact on plant risk. The risk impact is associated withthe TDAFW pump out-of-service for the duration of the enforcement discretion.

ICCDP and ICLERP were calculated using the following equations:

ICCDP = [Conditional CDF for TDAFW Out-of-Service

-Baseline CDF] * [TDAFWPump enforcement discretion outage duration]

ICLERP = [Conditional LERF for TDAFW Out-of-Service

-Baseline LERF] *[TDAFW Pump enforcement discretion outage duration]

The requested period of enforcement discretion was assumed to be 3 days beyondthe technical specification allowed outage time of 3 days (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). Theincremental risk associated with this period of operation is:ICCDP = [6.08E-06/yr

-2.47E-06/yr]

• [1 yr/365 days

• 3 days] = 2.97E-08ICLERP = [2.65E-07/yr

-3.65E-08/yr]

• [1 yr/365 days

• 3 days] = 1.88E-09The above risk assessment only addresses test and maintenance activities for theTDAFW for the duration of the NOED. All other test, maintenance andenvironmental conditions are assumed to be in their nominal condition.

Anydeviations will be addressed via the Risk Monitor (EOOS) and the MRule (a)(4)process.These results are below the NRC Inspection Manual, Chapter 0410 limits of 5E-7for ICCDP and 5E-8 for ICLERP.2. Discuss the dominant risk contributors (cut sets or sequences or both) andsummarize the risk insights for the plant-specific configuration the plantintends to operate in during the period of enforcement discretion.

Thisdiscussion should focus primarily on risk contributors that have changed Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 12 of 18(increased or decreased) from the baseline model because of the degradedcondition and resultant compensatory

measures, if any.The dominant sequences for Level 1 CDF with the TDAFW Pump unavailable areassociated with loss of offsite power, loss of a 4160V AC bus, and loss of a DCbus initiating events. This pump is also important for mitigating several internalflooding scenarios.

The LERF dominant sequences, in addition to the CDFdominant sequences, include mitigation of Steam Generator Tube Rupture (SGTR)initiating events. The important mitigating system is the motor-driven auxiliary feedwater pumps. The important operator action is re-establishing main feedwater and condensate to the steam generators.

Due to the risk implications with the TDAFW pump unavailable, no maintenance will be planned for the offsite power supply to the plant, the onsite electrical powersources, motor-driven auxiliary feedwater trains, main feedwater system, andcondensate system.3. Discuss how the compensatory measures are accounted for in the PRA.These modeled compensatory measures should be correlated, as applicable, to the dominant PRA sequences identified in items 1 and 2 above. Inaddition, other measures not directly related to the out-of-service equipment may also be implemented to reduce overall plant risk and, as such, shouldbe explained.

Compensatory measures that cannot be modeled in the PRAshall be assessed qualitatively.

The following compensatory measures will be taken:Implement the (a)(4) fire risk management actions in the Technical Requirements Manual (TRM) Section 7.4.1, Fire Related Safe ShutdownComponents:

o Review existing transient combustibles permits for the affected areaso Review existing ignition source permits for the affected areaso Perform an area walkdown of the affected areaso Evaluate all work requiring transient combustibles, hot work, orracking of breakers in the affected areaso Brief the shift operators and the fire brigade lead on the significance of a fire in the affected areaso Affected areas to be managed when the TDAFW pump is disabledare:" CB-1, Control Building West Switchgear Room -El. 4' 6"" CB-2, Control Building East Switchgear Room -El. 4' 6"" CB-8, Control Building Cable Spreading Area -El. 24' 6"" CB-9, Control Building Control Room -El. 47' 6"" CB-11, Control Building Instrument Rack Room Under floor -(-El.46' 6") and Rack Room -El. 47' 6"" SB-2, Service Bldg North Cable Tunnel -El. 4' 6"" SB-3, Service Bldg South Cable Tunnel -El. 4' 6" Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 13 of 18" ESF-1, ESF Bldg South Cntmt Recirc Cooler Cub -El. -34' 9" to36' 6"" ESF-2, ESF Bldg North Cntmt Recirc Cooler Cub -El. -34' 9" to36' 6"" ESF-4, ESF Bldg East Piping Area -El. 4' 6"" ESF-7, ESF Bldg Mechanical Equipment Room C -El- 36' 6" andESF Bldg Refueling Water Recirc Pumps Area -El- 21' 6"" ESF-8, ESF Bldg North MDAFW Pump Area -El. 24' 6"" ESF-9, ESF Bldg South MDAFW Pump Area -El. 24' 6" and ESFBldg Mechanical Equipment Room D -El- 36' 6"" Include area AS-1 D, Auxiliary Building West Floor Area -El. 24' 6" in theimplementation of (a)(4) fire risk management actions." An operator is continuously staged at the station blackout (SBO) dieselgenerator (DG) in accordance with Security Risk requirements.

" No planned unit transients, other than those described in the NOED for 4%downpower and associated full flow test, will be allowed for the duration ofthe NOED* No planned switchyard maintenance

• Protect the motor-driven auxiliary feedwater trains, main feedwater system,and condensate system* Removal of any of the components either due to scheduled or corrective maintenance will be monitored via the Risk Monitor (EOOS) and the MRule(a)(4) processNone of the compensatory measures listed above are directly accounted for in thePRA calculation of ICCDP and ICLERP. The actions are intended to increaseoperator awareness of plant conditions, to reduce the likelihood of losingredundant trains, and to reduce the likelihood and consequences of initiating events.4. Discuss the "extent of condition" of the failed or unavailable component(s) to other trains or divisions of equipment and the adjustments, if any, whichwere made to the related PRA common cause factors to account for potential increases in their failure probabilities.

The method used to determine theextent of condition shall be discussed.

It is recognized that a formal rootcause or apparent cause is not required because of the limited time available in determining the acceptability of a requested NOED. However, adiscussion of the likely cause shall be provided with an associated discussion of the potential for common cause failure.The extent of condition is limited to the TDAFW pump since the failure mechanism is associated with the turbine speed control function of the pump. No otherequipment in the AFW common cause component group shares this design formotive force. As a result, no adjustments have been made to the PRA to accountfor common cause factor and potential increases in common cause failureprobabilities.

Additionally, the MPS3 emergency diesel generators use controlsystems which are sufficiently different from the one used with the TDAFW pump Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 14 of 18(i.e. Woodward EGB versus Woodward PGG) such that the extent of condition isnot applicable to the MPS3 emergency diesel generators.

The MPS3 emergency diesel generators have been successfully tested and operated with no similaradverse conditions.

5. Discuss external event risk for the specified plant configuration.

An exampleof external event risk is a situation in which a reactor core isolation cooling(RCIC) pump has failed and a review of the licensee's Individual PlantExamination of External Events or full-scope PRA model identifies that theRCIC pump is used to mitigate certain fire scenarios.

Action may be taken toreduce fire ignition frequency in the affected areas and to reduce humanerror associated with time-critical operator actions in response to suchscenarios, and to ensure fire protective and corrective measures have beentaken.The MPS3 PRA is a level 1 and 2 (LERF) model that includes internal events andinternal floods. For external events (e.g., fire, seismic, external floods, high winds)the IPEEE is used for risk insights.

FireThe MPS3 internal events PRA does not include a fire model. Therefore, the firerisk is qualitatively assessed using the IPEEE. The IPEEE fire risk quantified aCDF impact by combining the frequency of fires and the probability ofdetection/suppression failure with the remaining safety function random failures.

Asystematic approach was used to identify critical fire areas where fires could failsafety functions and pose an increased risk of core damage if other safetyfunctions are unavailable.

The CDF due to fires is 4.8E-6/yr, with the dominant riskbeing fires in the cable spreading room, switchgear rooms, control room, andauxiliary building.

To mitigate the potential impact to fire risk, DNC will implement compensatory measures in accordance with the (a)(4) fire risk management actions in theTechnical Requirements Manual (TRM) Section 7.4.1. The compensatory actionsinclude the affected areas, cable spreading room (CB-8), switchgear rooms (CB-1and CB-2), and control room (CB-9). Though the TRM does not require fire riskmanagement actions for the Auxiliary Building location containing the Chargingand Reactor Building Component Cooling Water Pumps, fire zone AS-1 D has beenadded to the compensatory measures based on risk insights from the IPEEE.SeismicThe MPS3 internal events PRA does not include a seismic model. The IPEEEquantified a CDF impact by combining the seismic hazard frequencies with thefragilities of critical structures and components and the safety function randomfailures.

The CDF due to seismic events is 9.1E-06/yr, with the dominant riskbeing seismic events that result in a loss of offsite power and failure of the Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 15 of 18emergency diesel generator enclosures, or collapse of the control building.

Areview of the cutsets associated with loss of offsite power and early core melt(contributes 63% Seismic CDF) found that random failure of the auxiliary feedwater system does not significantly contribute to the seismic risk. Therefore, this NOEDwill not significantly impact the seismic risk.High Winds, External Floods, and Other EventsThe risk of other external events such as high winds, external

flooding, aircraftaccidents, hazardous materials, and turbine missiles was assessed in the MPS3IPEEE. The IPEEE assessments concluded that the risk of these accidents isnegligible primarily due to the low frequency of occurrence that would causedamage to mitigating systems.

For example, reinforced concrete houses providethe applicable safety systems missile protection during high winds. Note thepotential for high winds is covered under section n, which provides a discussion onforecasted weather.m. Demonstrate that the NOED condition, along with any compensatory

measures, will not result in more than a minimal increase in radiological risk, either in aquantitative assessment that risk will be within the normal work control levels(ICCDP less than or equal to 5E-7 and/or ICLERP less than or equal to 5E-8) orin a defensible qualitative manner.The PRA evaluation calculates the change in risk associated with an assumed 72 hourNOED for TDAFW Pump unavailability.

The ICCDP is 2.97E-08, which is below theNRC Inspection Manual, Chapter 0410 limit of 5E-7. The ICLERP is 1.88E-09, whichis below the 5E-8 threshold.

The risk impact is considered negligible andconsequently, the NOED poses no net increase in risk beyond normal work controllevels. As noted previously, any compensatory measures are not directly accounted for in the PRA calculation of ICCDP and ICLERP.n. Discuss forecasted weather and pandemic conditions for the requested NOEDperiod and any plant vulnerabilities related to weather or pandemic conditions.

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 16 of 18Daily Forecast for GROTON, CT (KGON)DSun Man ; Tue VWd Thu ; I I "

• MonDat 1/26 !1F27 1128 129 1 Fr/31 Sat2/1 'Sun 212 Mon2/3 Tue2A4 Wed2 25,Thu2/6 Fri 2/7 Sat2/8 Sun2/9 2110WeatherCondion E. 0 -Afternoon Weathr Rn .non ,, Partly Mostly Afternoon Partly Partly Flurries Snow Partly Snow Mostly Snow .PartlyWeter S ow ansunnSnn Cloudy Cloudy IFlurriesCluylodLieyieya P.ossibl

..uyoudy r Cloudy Cloudy Likely Likely Cloudy Likely Cloudy: Likely CloudyTemperature

• F) 17/31 22143 11(23 11129 15/33 25M40 26/42 29/42 26/35 25/38 23/46 22/34 20/31 1 18/31 19/31 17/32(LoIII)Feels Like (F) 2/22 12127 -2118 0/19 6/27 16/33 20/38 21/37 18/28 16/32 13/40 11/25 8/22 6122 7(21 5n24(Lo/14)Wet Bulb (*F) ',(Le/l) 13/29 17/43 8/17 9/22 12/28 24/33 25/41 27/42 24/32 25134 22/41 20/28 19/28 .17/26 18/28 16/2BDew Polnt (*F) 11 22 -3 1 2 11 22 26 28 24 27 22 18 20 156 19 20Humldity(*A 57 60 33 39 54 60 66 71 78 82 2 53 57 76 .62 7573Wind Speed (mph) 13 11 7 9 7 9 5 6 6 8 10 I 10 9 I 11Preclpltatdon 36 60 5 '060, 7 5Precipitation Rain S S 1/4 S:<1/4 I S:1-3 1S:144-1 N S1-3Amount Trace R None None None I None No ne No ne ,L:.25 None L0 ne N1ne(Raln:ln.Snow:ln.)

0.04 '0 L L .:'.06Evapotransplration Unchesiday) 0.06 0.07 1 0.05 0.06 0.05 r 0.05 0.04 0.04 0.03 0.03 0.08 0.05 003 0.04 0.03 0.03There are no additional plant vulnerabilities related to the weather conditions for theduration of the NOED.o. Include the basis for the licensee's conclusion the noncompliance will notcreate undue risk to public health and safety.The request for enforcement discretion to avoid an unnecessary plant shutdown as aresult of compliance with TS 3.7.1.2 ACTION c., by allowing an extension of theallowed outage time (AOT) for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for an inoperable auxiliary feedwater pump, does not result in a significant hazards consideration as defined in10 CFR 50.92. Specifically, the proposed enforcement discretion does not:* Involve a significant increase in the probability or consequences of an accidentpreviously evaluated.

The ICCDP, based on an assumed additional 72 hourAOT, is 2.97E-08, which is below the NRC Inspection Manual, Chapter 0410limit of 5E-7. The ICLERP, based on an assumed additional 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AOT, is1.88E-09, which is below the 5E-8 threshold.

The risk impact is considered negligible and consequently, the NOED poses no net increase in risk beyondnormal work control levels. As noted previously, any compensatory measuresare not directly accounted for in the PRA calculation of ICCDP and ICLERP.Allowing an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for the repairs associated with the TDAFWpump is acceptable since the AFW system remains capable of performing itsintended function.

During the extended maintenance and test period, thecompensatory actions identified in section J. will be implemented.

Therefore, the consequences of accidents related to or dependent on AFW systemoperation will not be significantly affected.

• Create the possibility of a new or different kind of accident from any accidentpreviously evaluated.

There are no new failure modes or mechanisms associated with plant operation for an extended period to perform maintenance and testing on the TDAFW pump. Extended operation with an inoperable TDAFW pump does not involve any modification in the operational limits or Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 17 of 18physical design of the involved systems.

Therefore, there are no new accidentprecursors generated due to the extended maintenance and testing period.Involve a significant reduction in a margin of safety. Plant operation for anadditional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with the inoperable TDAFW pump does not adversely affectthe margin of safety. During the extended maintenance and testing period theAFW system remains capable of performing its intended safety function.

Thecompensatory measures identified in section J. will remain in effect for the timeperiod when the proposed NOED will be used to assure safety margins aremaintained.

p. Include the basis for the licensee's conclusion the noncompliance will notinvolve adverse consequences to the environment.

The request for enforcement discretion does not change requirements with respect tothe installation or use of a facility component located within the restricted area, asdefined in 10 CFR 20, or would change an inspection or surveillance requirement.

Specifically, the request for enforcement discretion to avoid an unnecessary plantshutdown as a result of compliance with TS 3.7.1.2 ACTION c., does not involve (i) asignificant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released

offsite, or (iii) asignificant increase in individual or cumulative occupational radiation exposure.

Accordingly, the request for enforcement discretion meets the eligibility criteria forcategorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR51.22(b),

an environmental assessment for the request is not required.

q. Include a statement that the facility organization that normally reviews safetyissues has approved the request (Plant Onsite Review Committee, or itsequivalent).

The Facility Safety Review Committee has reviewed and concurs with this request.r. Make a verbal commitment that the licensee will submit the written NOEDrequest within 2 working days and a follow-up license amendment requestwithin 4 working days following the staff's verbal granting of the NOED. NRC'sgranting of a NOED means that exigent circumstances exist. However, thelicensee's amendment request must describe and justify any exigentcircumstances (see 10 CFR 50.91(a)(6)).

If the staff agrees during theconference call that a follow-up amendment request is not required, the licenseeshall state this in the written NOED request.

If the licensee intends to propose atemporary amendment, the licensee's amendment request shall includejustification for the temporary nature of the request.A license amendment is not being requested.

The requested NOED represents arequest for enforcement discretion for a temporary, specific period of time in whichMPS3 seeks to extend the AOT for TS ACTION 3.7.2.1 .c. for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> inorder to allow completion of repairs, and restore the TDAFW PUMP to OPERABLEstatus.

Serial No. 14-043Docket No. 50-423MPS3 AFW Request for Enforcement Discretion Attachment 1, Page 18 of 18s. In addition to items a thru r above, the licensee must provide the following information for a natural event NOED:1. List the name, organization, and telephone number of the official in thegovernment or independent entity who made the emergency determination, ifapplicable.

If deemed necessary, the staff may contact the appropriate official to independently verify the information the licensee provided beforemaking a NOED determination.

2. Include details of the basis and nature of the emergency including, but notlimited to, its effect on the following:

(a.) on-site and off-site emergency preparedness, (b.) plant and site ingress and egress,(c.) off-site and on-site power sources,(d.) plant security, (e.) grid stability, and(f.) actions taken to avert or alleviate the emergency situation (e.g.,coordinating with other utilities and the load dispatcher organization forbuying additional power or for cycling loads, or shedding interruptible industrial or non-emergency loads).3. Identify and discuss the potential consequences of compliance with existinglicense requirements (e.g., plant trip, controlled shutdown).

4. Discuss the potential adverse effects on public health and safety fromenforcing compliance with specific license requirements during theemergency.

5. Discuss the impact of the emergency on plant safety, including anylimitations of the UHS.6 For a grid instability NOED, assure the NRC that all reasonable opportunities for purchasing replacement power have been exhausted, and the NOED shallnot last any longer than replacement power becomes available, if applicable.

Not applicable as this is not a natural event NOED.